10326/RAP - Texas Commission on Environmental Quality

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Texas Commission on Environmental Quality
Texas Risk Reduction Program
Response Action Plan
Purpose
The purpose of this form is to provide a standard format for the Response Action Plan (RAP).
Objectives
These instructions provide information on the following:
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To whom does the RAP form apply?
When is the RAP submitted?
How is the RAP submitted?
How do I obtain more information?
How do I complete the RAP?
Regulatory Citation
30 TAC §350.94
Abbreviations and Acronyms
APAR – Affected Property Assessment Report
COC - chemical of concern
DOQQ – Digital Orthophoto Quarter Quads
EPA – Environmental Protection Agency
ESA - ecological services analysis
GPS – global positioning system
GW – groundwater
ID No. – Identification number assigned by the program area to the facility/site. Appropriate case/
tracking numbers include Solid Waste Registration (SWR) ID Number, VCP ID Number, etc.
LNAPL – light non-aqueous phase liquids
MC - mail code used by TCEQ for routing mail within the agency
MQL – method quantitation limit
NAPL – non-aqueous phase liquids
O&M - operation and maintenance
PCL – protective concentration level
PCLE – protective concentration level exceedance
PMZ – plume management zone
PRAC – post-response action care
PRP – potential responsible party
RACR – Response Action Completion Report
RAER– Response Action Effectiveness Report
RAP - Response Action Plan
RBEL – risk-based exposure limit
SWR - solid waste registration
TCEQ-10326/RAP February 2005
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TAC - Texas Administrative Code
TCEQ – Texas Commission on Environmental Quality
TI – technical impracticability
TRRP – Texas Risk Reduction Program
VCP – Voluntary Cleanup Program
WCU – waste control unit
General Instructions
Read these instructions carefully because the form itself does not contain all the instructions. You cannot
adequately complete the RAP without following these instructions. The RAP is not a guidance document.
You must consult the TRRP rule and associated guidance documents to develop your RAP.
To whom does the RAP form apply?
The RAP is submitted by persons who will be conducting response actions under the Texas Risk
Reduction Program (TRRP) rule to attain Remedy Standard B or for those persons who choose not to
self-implement response actions to attain Remedy Standard A.
When is the RAP submitted?
Submit the RAP to the TCEQ for review and approval prior to commencing response actions to attain
Remedy Standard B or non-self-implementing Remedy Standard A. This does not preclude the person
from taking interim measures. Submit the APAR with the RAP unless the APAR was submitted
previously. If the APAR was previously submitted and additional data has been collected since that time,
include an amended APAR with the RAP if the APAR worksheets are needed to convey the information,
or include the data in the RAP.
How is the RAP submitted?
Submit a copy of this form to both the applicable TCEQ program area in the Austin Central Office and to
the appropriate TCEQ Region Office. The mailing address and phone number for each of the Regional
Offices may be found at http://www.tceq.state.tx.us/AC/about/directory/region/reglist.html. The address
for the Central Office is:
TCEQ
[specify program area], MCP.O. Box 13087
Austin, Texas 78711-3087
How do I obtain more information?
The TRRP rule and guidance are available at http://www.tnrcc.state.tx.us/permitting/trrp.htm. You will
have to use the rule and associated guidance to complete your RAP. Questions regarding your affected
property should be addressed to the program area that is handling your case. Phone numbers for the
TCEQ programs are listed below.
Voluntary Cleanup Section
Superfund Cleanup Section
RPR Section
512/239-2478
512/239-2486
512/239-2200
TCEQ-10326/RAP February 2005
Corrective Action Section
512/239-2276
Municipal Solid Waste Permits 512/239-6784
2
How do I complete the RAP?
Carefully review these instructions and all instructions on the worksheets themselves. Failure to complete
the report as indicated may result in return of your report or a notice of deficiencies. Note that except
for expanding the narrative boxes with text, the form must not be modified in any way. Do not
change the numbering or the order of submittal of the worksheets, attachments, and appendices
even when portions are not included. When possible, please print the report on both sides of the pages.
Be sure to always include appropriate units of measurement in your answers.
All data must be supported with references and documentation. Unsubstantiated information may
be considered invalid.
The form is designed so that only the relevant worksheets are submitted depending on the site-specific
conditions and the components of the response action. Complete only the portions applicable to your
RAP. Complete the Checklist for Report Completeness to determine which sections are applicable for
your report. Arrange the worksheets, attachments, and appendices as specified in the RAP Contents list
below. Note that the form does not include many of the attachments and appendices because they do not
have prescribed formats (for example, laboratory reports). Place tabs in your bound report to clearly
identify each major section of the report as noted in the RAP Contents list on page 5.
If the on-site property is covered under a permit, any permit requirements that conflict with the
information in this document supercede this guidance.
Worksheets, Attachments, and Appendices
The following instructions are listed in order of the worksheets, attachments, and appendices as specified
in the RAP Contents list. All pages should include the regulatory ID number assigned to the on-site
property, the date of the report, and page numbers.
Cover Page - Specify the regulatory ID number assigned by the program area to the on-site property.
Appropriate ID numbers include Solid Waste Registration (SWR) ID Number, VCP ID number, or other
assigned number. If you do not know your regulatory ID number, contact the appropriate program area to
obtain that number before submitting this report. Specify the report date and indicate if this report is the
initial RAP for this affected property or if it is a subsequent submittal. Identify the TCEQ Region in
which the affected property is located. The list of region numbers is located at the end of the instructions.
Check the appropriate box to indicate the specific TCEQ program to which the report is submitted. The
TCEQ mailing address should include the appropriate TCEQ program and the corresponding mail code
(MC). If the report is being submitted to more than one program area, mail the reports separately and
address copies to each program with that program indicated on the cover page.
On-Site Property Information
Indicate the address of the on-site property (the area at which the assessment took place). Note that the
physical address is not a P.O. Box or a rural route. Include the following information for the on-site
property; example: 814 North 35th Street West
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street number (example: 814) Leave blank if none.
street predirectional - compass direction of the street address that occurs before the street name
(example: North). Leave blank if none.
street name (example: 35th) Leave blank if none.
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street type (example: Street) Leave blank if none.
street postdirectional - compass direction of the street address that occurs after the street name
(example: West). Leave blank if none.
 city
 county
 county code (see list at end of instructions)
 zip code
Specify the nearest street intersection or location description. For example, a location description may be:
“On FM 1055, 1 mile south of the intersection of FM 1055 and US Highway 57” or “On Main Street at
the intersection of Main Street and Broad Street.”
Specify the latitude and longitude near the center of the on-site property, either in terms of degrees,
minutes, seconds or decimal degrees. Indicate the units used. Refer to the definition of on-site property
in §350.4(a)(1). Horizontal positions collected using certified GPS units or by interpretation from 1meter Digital Orthophoto Quarter Quads (DOQQs) must maintain a minimum level of accuracy of at least
25 meters. Use of GPS equipment is strongly encouraged in the acquisition of coordinates for all
locations tracked by the TCEQ. Refer to the TCEQ document Attribute Standards for TCEQ Geographic
Locational Data and the TCEQ policies 8.11 and 8.12, available on the agency’s web page at
http://www.tnrcc.state.tx.us/gis/gisplcy.html.
Affected Off-Site Property Information
Include the address information in the format specified above for any affected off-site property(ies). If
there is more than one affected off-site property, attach additional pages to list the same information for
all affected off-site properties.
Contact Person for On-Site Property Information and Acknowledgement
Provide the identity and address of the person undertaking the response action (not the consultant).
Please refer to the definition of “person” in §350.4. The person should review the acknowledgement
carefully and must sign and date this form. The consultant is not allowed to sign this form.
Executive Summary – Use this section to summarize the major points of the report and provide
background information about the affected property.
Chronology – Attach a chronology, listed in chronological order beginning with the most recent activity,
of events associated with the assessment, all previous abatement and assessment activities, and all other
corrective actions conducted at the affected property. Include the date of actions taken and a brief
description of all release abatement activities, assessment activities, and response actions conducted.
Illustrate and label all locations of relevant information on the Affected Property map in Attachment 1A.
List all references, including the date, title, and preparer of previously submitted reports, in the reference
list in Appendix 1.
Checklist for Report Completeness - Use this checklist to identify the applicable worksheets for your
RAP and indicate which components are included in your report.
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RAP Contents
Worksheet 1.0
Attachment 1A*
Attachment 1B*
Worksheet 2.0
Attachment 2A*
Attachment 2B*
Attachment 2C*
Worksheet 2.1
Attachment 2D*
Attachment 2E*
Worksheet 2.2
Attachment 2F*
Worksheet 2.3
Attachment 2G*
Worksheet 2.4
Worksheet 3.0
Worksheet 3.1
Attachment 3A*
Worksheet 3.2
Worksheet 4.0
Attachment 4A*
Worksheet 5.0
Attachment 5A*
Attachment 5B*
Attachment 5C*
Worksheet 6.0
Appendix 1*
Appendix 2*
Appendix 3*
Appendix 4*
Appendix 5*
Appendix 6*
Appendix 7*
Appendix 8*
Cover Page
Executive Summary
Chronology
Checklist for Report Completeness
Section 1 Response Action Objectives
Response Action Objectives
Maps and Cross Sections
Graphs of Concentrations versus Time
Section 2 Response Action Design
Response Action Design
Response Action Diagrams and Component/Equipment Descriptions
Proposed Well Design
ESA and Compensatory Restoration Plan
Plume Management Zone
Plume Management Zone Map
Attenuation Action Levels Determination
Waste Control Unit
Map of Waste Control Unit
Technical Impracticability
Map of Technical Impracticability Area
Institutional Controls
Section 3 Response Action Performance
Performance Measures and Potential Problems
Monitoring and Sampling
Map of Monitoring and Sampling Points
Operation and Maintenance
Section 4 Confirmation Sampling
Confirmation Sampling Plan
Map of Confirmation Sampling Points
Section 5 Post-Response Action Care
Post-Response Action Care
Map of Post-Response Action Care Monitoring and Sampling Points
Post-Response Action Care Costs
Small Business Affidavit
Section 6 Implementation Schedule
Implementation Schedule
Appendices
References
Data Tables and Boring Logs
Studies/tests documentation
Proposed Institutional Controls
Landowner Concurrence
Sampling Procedures
Statistical Methodology
Split Media Approval
*These items are not included in the form and are provided by the person.
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SECTION 1 – Response Action Objectives
Worksheet 1.0 Response Action Objectives – Use this worksheet to describe the objectives of the
response action. For each environmental media (surface soil, subsurface soil, groundwater, surface water,
sediment, or air) containing a PCLE zone, state the response objectives for the PCLE zone(s) and how the
response action will meet the remedy standard objectives in the proposed reasonable time. Refer to Soil
and Groundwater Response Objectives (RG-366/TRRP-29) for more information on response action
objectives.
Attachment 1A Maps and Cross Sections – Unless the most recent and current data was included in the
APAR, provide the following to document the most current and recent data:
Affected Property Map – Include a large-scale map that illustrates all aspects of the affected property.
Indicate the affected property boundary (this is not the legal property boundary) as defined by the
assessment levels and the overall PCLE zone as defined by the critical PCLs. Include legal property
boundaries, buildings and other structures, adjacent roads, all potential source areas and known release
areas, land uses, type of surface cover, subsurface utilities, surface drainage, surface water bodies, boring
and monitor well locations, other sampling locations, cross-section lines, water supply wells, and any
other potential receptors. Required legend information: north arrow, fractional and bar scales, map source
and identification of all symbols used on the map.
COC Concentration Maps - Provide affected property map(s) to visually present analytical data. The
maps, typically one map per significant COC per media, drawn to scale, should illustrate all sampling
points, COC concentrations, isoconcentration contours including a contour of the critical PCL to delineate
the PCLE zone, sample depth intervals, and relevant surface and subsurface features. When there is
sufficient time series data, also construct maps for significant COCs using previous sampling dates to
illustrate PCLE zone changes over time. Required legend information: north arrow, fractional and bar
scales, and identification of all symbols used on the map.
Parameters Maps - Provide maps as necessary to effectively illustrate the distribution of geochemical
and geotechnical parameters (such as fraction organic carbon and bulk density) when such information is
collected. Illustrate on maps drawn to scale all sampling points, geochemical and geotechnical
concentrations and values, isoconcentration contours as appropriate to accurately depict the data in each
media, sample depth intervals, and relevant surface and subsurface features. Required legend
information: north arrow, fractional and bar scales, and identification of all symbols used on the map.
Groundwater Gradient Map - Provide a groundwater gradient map, drawn to scale, illustrating all
monitoring wells, groundwater surface elevation in feet AMSL or BMSL, labeled groundwater elevation
contours, and groundwater flow direction. If groundwater elevation data was collected at several times
and the groundwater flow magnitude or direction has changed over time, submit a sufficient number of
maps to illustrate these changes. Required legend information: north arrow, fractional and bar scales, and
identification of all symbols used on the map.
Cross Sections - If new data results in modification of data from that provided in the APAR, provide a
minimum of two cross-sections perpendicular to each other through the source area and affected property.
For sites with monitor wells, construct one cross section approximately parallel to the groundwater flow
direction and one approximately perpendicular to flow direction. Illustrate site stratigraphy using the
boring logs through the total depth of the borings/monitor wells or water well if used in the cross section.
Indicate all groundwater-bearing units, lithologies, designated surface and subsurface soils, areas
exceeding the assessment level and critical PCL (PCLE zones) for each media, including the location,
depth, and extent of NAPL, static groundwater level, monitor well screened intervals, aquitards, migration
TCEQ-10326/RAP February 2005
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pathways, subsurface conduits and the compass directions of the cross sections. Required legend items:
horizontal and vertical scales and identification of all symbols used in the cross section. Indicate the cross
section lines on the affected property map. Additional cross sections may be submitted as needed to
effectively portray subsurface conditions.
Attachment 1B Graphs of Concentration versus Time – Provide graphs of concentration versus time for
significant COCs in critical monitor wells or other media sampling points. The most recent and current
data must be used in the graphs. If the most recent and current data was used to construct these graphs in
the APAR, this attachment does not need to be repeated in the RAP.
SECTION 2 – Response Action Design
Worksheet 2.0 Response Action Design – Provide a detailed description of the response action design
for each media. Complete a separate worksheet for each different response action.
Attachment 2A Response Action Diagrams and Component/Equipment Descriptions – Illustrate in
maps, drawings, and diagrams the design and layout of equipment and components. The plan should
clearly show: the location of all key equipment; the location and coverage of any proposed physical
control; the area in which the response action will occur; recovery, monitoring, or injection wells;
buildings; surface cover types; and surface drainage. Include equipment manufacturers' documentation
that identifies equipment construction and performance measurements. Required legend information for
maps: north arrow, fractional and bar scales, map source and identification of all symbols used on the
map.
Attachment 2B Proposed Well Design – Illustrate the proposed design and placement of any proposed
monitor wells, recovery wells, or injection wells using construction diagrams and a map of proposed
locations. Required legend information for maps: north arrow, fractional and bar scales, map source and
identification of all symbols used on the map.
Attachment 2C Ecological Services Analysis and Compensatory Restoration Plan – Use this
attachment to provide an ecological services analysis (ESA) and compensatory restoration plan if
proposed as part of the response action. Guidance discussing ESAs and compensatory restoration is
provided in Guidance for Conducting Ecological Risk Assessments in Texas, available on the TCEQ web
page.
Worksheet 2.1 Plume Management Zone – Complete this worksheet when a plume management zone is
proposed as part of the response action. Refer to Soil and Groundwater Response Objectives (RG366/TRRP-29) for more information on plume management zones.
Attachment 2D PMZ Map - Provide a map that illustrates the area of the plume management zone, the
attenuation monitoring points, alternate groundwater POEs, and the groundwater PCLE zone. Note all
receptors within the PMZ and any potentially threatened receptors outside the PMZ. Illustrate major
buildings, structures, roads, and other major site features. Required legend information: north arrow,
fractional and bar scales, map source and identification of all symbols used on the map.
Attachment 2E Attenuation Action Levels Determination – Provide in this attachment all equations,
calculations, and other methods of determining the attenuation action levels for each attenuation
monitoring point. Provide supporting documentation for the justification that the PMZ is appropriate in
accordance with §350.33(f)(4).
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Worksheet 2.2 Waste Control Unit – Use this worksheet to provide information on the waste control unit
if proposed as part of the response action. Do not submit this worksheet if a waste control unit is not part
of the response action plan. Refer to Soil and Groundwater Response Objectives (RG-366/TRRP-29) for
more information on response action objectives.
Attachment 2F Waste Control Unit Map – Include a map that illustrates the waste control unit, the
groundwater flow direction, the groundwater PCLE zone, and all major site features. Required legend
information: north arrow, fractional and bar scales, map source and identification of all symbols used on
the map.
Worksheet 2.3 Technical Impracticability – Use this worksheet to provide information on a technical
impracticability demonstration. If a technical impracticability demonstrate is not proposed, do not submit
this worksheet or Attachment 2G. Refer to Soil and Groundwater Response Objectives (RG-366/TRRP29) for more information on response action objectives.
Attachment 2G Technical Impracticability Map – Provide a map that illustrates the area of technical
impracticability, the groundwater flow direction, the groundwater PCLE zone, and all major site features.
Required legend information: north arrow, fractional and bar scales, map source and identification of all
symbols used on the map.
Worksheet 2.4 Institutional Controls – Complete this worksheet if an institutional control will be used
as part of the response action. Repeat this worksheet for each property that requires an institutional
control. Refer to Institutional Controls (RG-366/TRRP-16) for further information on institutional
controls.
Section 3 Response Action Performance
Worksheet 3.0 Performance Measures and Potential Problems – Describe the performance measures
that will be used to determine if reasonable progress is being made by the response action. The
performance measures must clearly demonstrate that the response actions addressing each media are
being accomplished in a reasonable time. If statistical or geostatistical methods will be used as part of the
effectiveness measures, discuss the assumptions and provide the equations for statistical or geostatistical
methodology(ies) in Appendix 7. The results of the measures of effectiveness will be reported in the
RAER and RACR to document that the response action is proceeding in a timely manner.
Describe any potential problems that may occur with, or during, the response action. The description
should demonstrate that potential problems have been anticipated and that contingency measures are in
place. List potential problem that might be reasonably anticipated for a response action of this type, and
that might result in response action failure and/or downtime. Describe the impact of the problem on the
response action, and describe how the risk of each scenario will be minimized through duplicate systems,
inspection and maintenance, preventive maintenance/parts replacements, and operational guidelines.
Also describe the training, equipment, and assets that will be utilized in a timely manner for each
response to a problem.
Worksheet 3.1 Monitoring and Sampling – Specify the monitoring and sampling that will be conducted
to assess the effectiveness and progression of the response action. Discuss the sampling methods in
Appendix 6 unless the planned monitoring or sampling procedure is the same as the media sampling
procedures described in the APAR.
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Attachment 3A Map of Monitoring and Sampling Points – Provide maps showing the monitoring and
sampling points in each media, the PCLE zone, and all major features of the site. Required legend
information: north arrow, fractional and bar scales, map source and identification of all symbols used on
the map.
Worksheet 3.2 Operation and Maintenance –Provide a brief overview of the operation and maintenance
activities. List the key operating parameters considered important to the proper operation of the response
action and critical to its effectiveness. Provide the detail necessary to explain how the person will know
the response action is functioning properly. List routine tasks required to operate and maintain the
response action, including scheduled inspections, maintenance, and component replacement.
SECTION 4 – Confirmation Sampling
Worksheet 4.0 Confirmation Sampling Plan – Specify the COC or other parameter sampling that will be
conducted in each media requiring a response action to confirm completion of the response action.
Discuss the sampling methods in Appendix 6 unless the methods are the same as the media sampling
procedures described in the APAR. Illustrate the sampling locations in Attachment 4A.
Attachment 4A Map of Confirmation Sampling Points – Provide maps, drawn to scale, to illustrate the
confirmation sample points in each media requiring a response action and all major site features.
Required legend information: north arrow, fractional and bar scales, map source and identification of all
symbols used on the map.
SECTION 5 – Post Response Action Care
Worksheet 5.0 Post-Response Action Care – Complete this worksheet for Remedy Standard B response
actions. Describe the proposed post-response action care (PRAC) activities, including the type of
monitoring and/or inspection to be performed for each environmental media requiring a response action.
Attachment 5A Map of Post-Response Action Care Monitoring and Sampling Points – Provide map(s)
illustrating the affected property, limits of proposed physical controls, all proposed PRAC monitoring,
sampling, and inspection points. Required legend information: north arrow, fractional and bar scales,
map source and identification of all symbols used on the map.
Attachment 5BA Post Response Action Care Costs – Provide a detailed cost estimate for a third party to
operate and maintain the physical control during the post response action care period.
Attachment 5C Small Business Affidavit – When the person is a small business who desires to pursue the
reduced amount of financial assurance, include the small business affidavit to meet the requirements of 30
TAC §350.33(n)(2). An example affidavit is included on page 12.
SECTION 6 – Implementation Schedule
Worksheet 6.0 Implementation Schedule – Provide a detailed project schedule of proposed response
action activities. Include the proposed duration, start/finish dates, and the proposed date of submittal of
the applicable reports or notifications following approval of the RAP. You may list start and finish dates
as actual (approximate) dates or as time from RAP approval. The RAER must be submitted a minimum
of every three years following from the date of approval of the RAP. The RACR must be submitted
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within 90 days of completion of a response action, and the PRACR is due each anniversary of the date of
TCEQ approval of the RACR, unless an alternate reporting schedule is approved by the TCEQ.
Appendices
Appendix 1 Reference List – In order to document the sources of information included in this report,
provide a complete list of references, including personal communications, reports, books, published and
unpublished documents, databases, maps, and any other sources of information used in this report. Each
reference should specify, as applicable, the author, date, title of article, title of book, periodical, or report,
publisher, date of publication, issue information (edition, volume, issue number, date); page reference,
and URL. Database references should include the source of the database, the name of the database, and
the date the information was acquired. Personal communication references should include the name of
the person contacted, the date of contact, and the method of contact (phone, letter, etc). Clearly identify
each item in the report that has a reference in this appendix using either superscript numbers or authordate citation (for example, Adams 1999). List references in the order in which they appear in each
worksheet and attachment, clearly identifying on which worksheet or attachment the item appears. Please
note that unsubstantiated information may be considered invalid.
Appendix 2 Data Tables and Boring Logs – Use this attachment to provide boring logs and tables of data
collected since submittal of the APAR (unless previously submitted).
COC Data Tables - Provide summary tables of all media sample screening and analytical results
obtained since the submittal of the APAR. Include the following: COC, the critical PCL for each COC,
method quantitation limit, sample ID no., sample date, sample depth, and concentration in mg/kg, mg/L,
or other appropriate measure. Highlight the individual results that exceed the critical PCL. If the result
was not quantifiable, specify that the concentration was less than the SQL for that sample (for example,
<0.01 mg/kg). Results of field screening of soil samples should be specified in a separate table in this
attachment. The SQL may be used in place of the MQL if it is satisfactorily demonstrated that all
reasonably available analytical technology has been used to show that the COC cannot be measured to the
MQL due to sample specific interferences. If such a demonstration is made, include all supporting
information in this appendix.
Parameters Data Table - Provide summary tables of the results of any geochemical or geotechnical
analyses. The tables should include the parameter analyzed, sample date, method quantitation limit
(MQL), analytical method, type of media, sample ID no., sample depth, and result. If the result was
nondetect, specify the SQL for that parameter (do not only write “ND”).
Groundwater Measurements Table - Include in this attachment a summary table of all monitor well and
water well gauging data. The table should include: depth to groundwater, NAPL thickness, groundwater
elevation in relation to mean sea level, top of casing and/or ground surface elevations (specify measuring
point), corrected water level and well screen interval. The table should be organized with all results for
each monitor well or water well listed in date order (oldest first). If measurable LNAPL is present,
provide the specific gravity of the LNAPL and the equation used to calculate the corrected groundwater
elevation.
Boring Logs and Monitor Well Completions- If any borings or monitor wells were installed since
submittal of the APAR, provide soil boring logs which include lithology, identification of groundwaterbearing units, field-screening results, sample locations, sample type (discrete, composite), total depth,
sampling tool, boring diameter, depth at which groundwater was encountered while drilling, drilling
method, and, if applicable, monitor well completion details including screened interval, diameter, and slot
size, casing interval and diameter, cement and grout intervals.
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Appendix 3 Studies and Tests Documentation – Provide complete details on any studies or tests already
conducted or proposed as part of this response action. Include test methods, purpose of the test, results (if
already conducted), and how the results will be, or have been, used to choose the response action, design
the response action or modify the response action. If modeling was used, provide documentation of the
software and model used, all input data assumptions, and all results.
Appendix 4 Proposed Institutional Controls – Provide a draft of the proposed institutional controls
identified in Worksheet 2.4.
Appendix 5 Landowner Concurrence – Provide a map of the properties and a list of landowners from
whom concurrence will be requested to execute an institutional control. Include documentation of any
landowner concurrence already received.
Appendix 6 Sampling Procedures - Attach a written description of sample collection and handling
procedures if the procedures are different from the procedures previously provided in the APAR (if so,
specify the report name and submittal date in which the sample collection and handling procedures are
described). Identify and describe the proposed field screening and/or sampling method(s) to be used, the
method of sample collection and preservation, and sample handling procedures. Discuss the site-specific
reasons for choosing the sample collection and handling method(s). Include a discussion of the data
quality objectives for the project.
Appendix 7 Statistical Methodology – Define the statistical or geostatistical methodology(ies) that will be
applied in the data collection or data evaluation process. Discuss the basis for assumptions and provide
all equations that will be used.
Appendix 8 Split Media Approval – Use this appendix to provide a copy of the TCEQ-issued approval to
apply the procedures on managing media under different plans of action.
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County Codes and TCEQ Region Numbers
County
Anderson
Andrews
Angelina
Aransas
Archer
Armstrong
Atascosa
Austin
Bailey
Bandera
Bastrop
Baylor
Bee
Bell
Bexar
Blanco
Borden
Bosque
Bowie
Brazoria
Brazos
Brewster
Briscoe
Brooks
Brown
Burleson
Burnet
Caldwell
Calhoun
Callahan
Cameron
Camp
Carson
Cass
Castro
Chambers
Cherokee
Childress
Clay
Cochran
Coke
Coleman
Collin
Collingsworth
Colorado
County
Code
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
Region
No.
5
7
10
14
3
1
13
12
2
13
11
3
14
9
13
11
7
9
5
12
9
6
1
15
3
9
11
11
14
3
15
5
1
5
1
12
5
1
3
2
8
3
4
1
12
County
Code
Comal
Comanche
Concho
Cooke
Coryell
Cottle
Crane
Crockett
Crosby
Culberson
Dallam
Dallas
Dawson
Deaf Smith
Delta
Denton
DeWitt
Dickens
Dimmit
Donley
Duval
Eastland
Ector
Edwards
Ellis
El Paso
Erath
Falls
Fannin
Fayette
Fisher
Floyd
Foard
Fort Bend
Franklin
Freestone
Frio
Gaines
Galveston
Garza
Gillespie
Glasscock
Goliad
Gonzales
Gray
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
61
62
63
64
65
66
67
68
69
70
71
72
73
74
75
76
77
78
79
80
81
82
83
84
85
86
87
88
89
90
TCEQ-10326/RAP February 2005
Reg
No.
13
3
8
4
9
3
7
8
2
6
1
4
7
1
5
4
14
2
16
1
16
3
7
13
4
6
4
9
4
11
3
2
3
12
5
9
13
7
12
2
13
7
14
14
1
County
Grayson
Gregg
Grimes
Guadalupe
Hale
Hall
Hamilton
Hansford
Hardeman
Hardin
Harris
Harrison
Hartley
Haskell
Hays
Hemphill
Henderson
Hidalgo
Hill
Hockley
Hood
Hopkins
Houston
Howard
Hudspeth
Hunt
Hutchinson
Irion
Jack
Jackson
Jasper
Jeff Davis
Jefferson
Jim Hogg
Jim Wells
Johnson
Jones
Karnes
Kaufman
Kendall
Kenedy
Kent
Kerr
Kimble
King
Code Reg
No.
91
4
92
5
93
9
94
13
95
2
96
1
97
9
98
1
99
3
100
10
101
12
102
5
103
1
104
3
105
11
106
1
107
5
108
15
109
9
110
2
111
4
112
5
113
10
114
7
115
6
116
4
117
1
118
8
119
3
120
14
121
10
122
6
123
10
124
15
125
14
126
4
127
3
128
13
129
4
130
13
131
15
132
3
133
13
134
8
135
2
County
Code
Kinney
Kleberg
Knox
Lamar
Lamb
Lampasas
La Salle
Lavaca
Lee
Leon
Liberty
Limestone
Lipscomb
Live Oak
Llano
Loving
Lubbock
Lynn
McCulloch
McLennan
McMullen
Madison
Marion
Martin
Mason
Matagorda
Maverick
Medina
Menard
Midland
Milam
Mills
Mitchell
Montague
Montgomery
Moore
Morris
Motley
Nacogdoches
Navarro
Newton
Nolan
Nueces
Ochiltree
Oldham
136
137
138
139
140
141
142
143
144
145
146
147
148
149
150
151
152
153
154
155
156
157
158
159
160
161
162
163
164
165
166
167
168
169
170
171
172
173
174
175
176
177
178
179
180
12
Reg
No.
16
14
3
5
2
9
16
14
11
9
12
9
1
14
11
7
2
2
8
9
16
9
5
7
8
12
16
13
8
7
9
9
3
3
12
1
5
2
10
4
10
3
14
1
1
County
Orange
Palo Pinto
Panola
Parker
Parmer
Pecos
Polk
Potter
Presidio
Rains
Randall
Reagan
Real
Red River
Reeves
Refugio
Roberts
Robertson
Rockwall
Runnels
Rusk
Sabine
San Augustine
San Jacinto
San Patricio
San Saba
Schleicher
Scurry
Shackelford
Shelby
Sherman
Smith
Somervell
Starr
Stephens
Sterling
Stonewall
Sutton
Swisher
Tarrant
Taylor
Terrell
Terry
Throckmorton
Titus
Code Reg.
No.
181 10
182 4
183 5
184 4
185 1
186 7
187 10
188 1
189 6
190 5
191 1
192 8
193 13
194 5
195 7
196 14
197 1
198 9
199 4
200 3
201 5
202 10
203 10
204 10
205 14
206 9
207 8
208 3
209 3
210 10
211 1
212 5
213 4
214 15
215 3
216 8
217 3
218 8
219 1
220 4
221 3
222 7
223 2
224 3
225 5
County
Code Reg
No.
Tom Green 226 8
Travis
227 11
Trinity
228 10
Tyler
229 10
Upshur
230 5
Upton
231 7
Uvalde
232 13
Val Verde
233 16
Van Zandt
234 5
Victoria
235 14
Walker
236 12
Waller
237 12
Ward
238 7
Washington 239 9
Webb
240 16
Wharton
241 12
Wheeler
242 1
Wichita
243 3
Wilbarger
244 3
Willacy
245 15
Williamson 246 11
Wilson
247 13
Winkler
248 7
Wise
249 4
Wood
250 5
Yoakum
251 2
Young
252 3
Zapata
253 16
Zavala
254 16
EXAMPLE
To be used as RAP Attachment 5C
SMALL BUSINESS AFFIDAVIT
FOR COMPLIANCE WITH 30 TAC §350.33(n)(1)
STATE OF TEXAS
COUNTY OF {___________________}
AFFIDAVIT OF {NAME OF AFFIANT}
Before me, the undersigned notary, on this day personally appeared {name of affiant}, a
person whose identity is known to me. After I administered an oath to {him/her}, upon
{his/her} oath, {he/she} said:
My name is {name of affiant}. I am capable of making this affidavit. The facts stated in
this affidavit are within my personal knowledge and are true and correct.
I am the owner or an authorized officer of {name of business} which is a small business
as defined by 30 TAC §350.33(n)(2). {Name of business} employs, by direct payroll and/or
through contract, fewer than one hundred full time employees, has net annual receipts (as defined
by 30 TAC §350.33(n)(2)(A)) of less than $3,000,000, and is not a wholly-owned subsidiary of a
corporation which has one hundred or more full time employees and net annual receipts (as
defined by 30 TAC §350.33(n)(2)(A)) of $3,000,000 or more.
SWORN TO AND SUBSCRIBED before me by {name of affiant} on
_____________________, (year).
___________________________
Notary Public in and for
The State of Texas
My commission expires: {date}
TCEQ-10326/RAP February 2005
13
TEXAS COMMISSION ON ENVIRONMENTAL QUALITY
Response Action Plan
Cover Page
Regulatory ID number (Solid waste registration number, VCP ID number, etc)
check one:
Initial submittal for this on-site property
Subsequent submittal for this on-site property
Report date:
TCEQ Region No.:
TCEQ Program (check one)
Corrective Action (Mail Code 127)
Superfund PRP Lead (Mail Code 143)
Voluntary Cleanup Program (Mail Code 221)
Municipal Solid Waste Permits (Mail Code 124)
RPR Section (Mail Code 137)
On-Site Property Information
On-Site Property Name:
Street no.
Pre dir:
Street name
City:
Street type:
County:
Post dir:
County Code:
Zip:
Nearest street intersection or location description:
Latitude: Degrees, Minutes, Seconds OR Decimal Degrees (circle one) North
Longitude: Degrees, Minutes, Seconds OR Decimal Degrees (circle one) West
Off-Site Affected Property Information
Off-Site Affected Property Name:
Physical Address:
Street no.
City:
Pre dir:
Street name
Street type:
County:
Post dir:
County Code:
Zip:
Check if no off-site properties affected
Contact Person Information and Acknowledgement
Person (or company) Name:
Title:
Contact Person:
Mailing Address:
City:
Phone:
State:
Zip:
E-mail address
Fax:
By my signature below, I acknowledge the requirement of §350.2(a) that no person shall submit
information to the executive director or to parties who are required to be provided information under this
chapter which they know or reasonably should have known to be false or intentionally misleading, or fail
to submit available information which is critical to the understanding of the matter at hand or to the basis
of critical decisions which reasonably would have been influenced by that information. Violation of this
rule may subject a person to the imposition of civil, criminal, or administrative penalties.
Signature of Person
TCEQ-10326/RAP February 2005
Name, print:
Date:
14
RAP Executive Summary
ID No.:
Report Date:
Use this worksheet to summarize the report. Be sure to complete and submit the Checklist for Report
Completeness. Attach a chronology of activities associated with the affected property.
Briefly describe the affected property and PCLE zones, the conclusions from the assessment activities,
identify any affected or threatened receptors, and describe any other major considerations taken into
account when developing this response action plan. If any portion of the response action is necessitated
due to an aesthetic or nuisance condition, identify the nature of that condition and identify that portion of
the response action proposed to address it. If any media that contains a PCLE zone is not addressed in
this RAP, provide justification.
What is the selected remedy standard for this affected property?
A
B
List all media that contains a PCLE zone and specify the proposed response action for each media.
Indicate the type of removal, decontamination, physical control and/or institutional control action that is
proposed.
Media
COCs1
Removal
Decontamination
Physical
Control
Control
Modified Groundwater Response
Objective2
PMZ
WCU
TI
Is there a media that contains a PCLE zone that is not addressed in this RAP?
If yes, provide justification for not addressing the PCLE zone in this RAP.
On-site land use:
Off-site land use:
Residential
Residential
Commercial/Industrial
Commercial/Industrial
Is this a re-submittal or revision of a previous RAP?
Yes
If yes, explain why the RAP is being revised or resubmitted.
yes
no
(check all that apply)
No
Were all the appropriate notifications made in accordance with §350.55?
If no, explain why notifications were not made:
Yes
No
1
Specify either a specific COC or, if the response action is the same for all COCs in one type, specify the type of
COC (for example, VOCs, SVOCs, metals).
2 If a modified groundwater response objective is proposed, check the type(s) of proposed modifications.
TCEQ-10326/RAP February 2005
15
Checklist for Report Completeness
ID No.:
Report Date:
Use this checklist to determine the portions of the form that must be submitted for this report. Answer all questions by
checking Yes or No. If the answer is Yes include that portion of the report. If the answer is No, do not complete or submit
that portion of the report. All form contents that are marked "Required" must be submitted. Form contents marked with an
asterisk (*) are not included in the blank form and are to be provided by the person.
Report
Contents
No
Have new data been collected that was not previously
submitted?
Required
Cover Page
Required
Executive Summary
Required
Checklist for Report
Completeness
Required
Worksheet 1.0
Response Action Objectives
Yes
Attachment 1A*
Maps and Cross Sections
Attachment 1B*
Graphs of Concentration versus
Time
Required
Worksheet 2.0
Response Action Design
Required
Attachment 2A*
Response Action Diagrams and
Component/Equipment
Descriptions
Required
Attachment 2B*
Proposed Well Design
No
Is an ecological services analysis or compensatory
restoration plan part of the proposed response action?
Yes
Attachment 2C*
ESA and Compensatory
Restoration Plan
No
Is a plume management zone proposed as part of the
response action?
Yes
Worksheet 2.1
Plume Management Zone
Attachment 2D*
Plume Management Zone Map
Attachment 2E*
Attenuation Action Levels
Determination
No
Is a waste control unit proposed as part of the response
action?
Yes
Worksheet 2.2
Waste Control Unit
Attachment 2F*
Map of Waste Control Unit
No
Is a technical impracticability area proposed as part of the
response action?
Yes
Worksheet 2.3
Technical Impracticability
Attachment 2G*
Map of Technical
Impracticability Area
TCEQ-10326/RAP February 2005
16
Checklist for Report Completeness
ID No.:
Report Date:
Report
Contents
No
No
Is the response action a remedy standard B?
Is the response action a Remedy Standard B?
Yes
Worksheet 2.4
Institutional Controls
Required
Worksheet 3.0
Performance Measures and
Potential Problems
Required
Worksheet 3.1
Monitoring and Sampling
Required
Attachment 3A*
Map of Monitoring and Sampling
Points
Required
Worksheet 3.2
Operation and Maintenance
Required
Worksheet 4.0
Confirmation Sampling Plan
Required
Attachment 4A*
Map of Confirmation Sampling
Points
Yes
Worksheet 5.0
Post Response Action Care
Attachment 5A*
Map of PRAC Monitoring and
Sampling Points
Attachment 5B*
PRAC Costs
No
Does the person, who is a small business, desire to
modify the financial assurance requirement?
Yes
Attachment 5C*
Small Business Affidavit
Required
Worksheet 6.0
Implementation Schedule
Required
Appendix 1*
References
No
Was any data collected that was not previously
reported?
Yes
Appendix 2*
Data Tables and Boring Logs
No
Were any studies or tests conducted?
Yes
Appendix 3*
Studies and Tests
Documentation
No
Is the response action a Remedy Standard B?
Yes
Appendix 4*
Proposed Institutional Controls
No
Are any institutional controls proposed/required on
property not owned by the person?
Yes
Appendix 5*
Landowner Concurrence
No
Are any of the sample collection or handling
procedures different from those reporting in the APAR
or other previously submitted report?
Yes
Appendix 6*
Sampling Procedures
No
Are statistics or geostatistics proposed to be used as
part of the response action?
Yes
Appendix 7*
Statistical Methodology
No
Was approval received from the TCEQ regarding the
use of different rules to address a media?
Yes
Appendix 8*
Split Media Approval
Form contents marked with an asterisk (*) are not included in the blank form.
TCEQ-10326/RAP February 2005
17
Response Action Objectives
Associated Information: Attachment 1A, 1B
RAP Worksheet 1.0
ID No.:
Page ___ of ____
Report Date:
Use this worksheet to describe the objectives for the response action in each media.
Response Action Objectives
List the environmental media to which this applies
Repeat this section for each medium that has a different response action objective.
State the property-specific response objectives for the PCLE zone in each media in the context of the
response objectives set forth in §350.32 or §350.33 as applicable. Explain how the response action is
appropriate based on the hydrogeologic characteristics, COC characteristics, and potential unprotective
conditions that could continue or result during the remedial period.
Explain how the COCs will be handled, treated, disposed, or transferred to another media and document
that the response action will not result in any additional potential exposure conditions due to response
action activities.
State the proposed “reasonable time frame” and provide the justification for that time frame in the context
of any potential for unprotective exposures to exist or develop, COC characteristics, hydrogeologic and
affected property characteristics. If the reasonable time frame is different for the different affected media
or for particular tracts of land, be sure to discuss that. Provide how the proposed response action will
meet the objectives in a reasonable timeframe.
Soil Response Action Objectives
When using removal and/or decontamination with controls or controls only, demonstrate how that
physical control or combination of measures will reliably contain COCs within and/or derived from the
surface soil and subsurface soil PCLE zone materials over time.
Explain how the removal or decontamination action will reduce the concentration of COCs to the critical
surface soil and subsurface soil PCL throughout the soil PCLE zone and prevent COC concentrations
above the critical soil PCLs from migrating beyond the existing boundary of the soil PCLE zone.
TCEQ-10326/RAP February 2005
18
Response Action Objectives
Associated Information: Attachment 1A, 1B
RAP Worksheet 1.0
ID No.:
Page ___ of ____
Report Date:
Groundwater Response Action Objectives
Name of groundwater-bearing unit to which this information
applies
Repeat this section for each groundwater-bearing unit for which a different response action is proposed.
Groundwater classification
1
2
3
Is a modified groundwater response action being proposed for any part of the
groundwater PCLE zone (§350.33(f)(2), (3), or (4))?
If yes, does the affected property meet the qualifying criteria for a modified groundwater
response action using a waste control unit, plume management zone, or technical
impracticability?
If yes, complete the appropriate portions of this report.
If no to either question, complete the following:
Yes
Yes
No
No
Explain how the removal or decontamination action will reduce the concentration of COCs to the critical
groundwater PCL throughout the groundwater PCLE zone and prevent COC concentrations above the
critical groundwater PCL from migrating beyond the existing boundary of the groundwater PCLE zone.
Explain how the response action will prevent COCs from migrating to air at concentrations above the
PCLs for air if the groundwater-to-air PCLs (AirGW Inh-V) is exceeded.
Explain how the response action will prevent COCs from migrating to surface water at concentrations
above the PCLs for groundwater discharges to surface water if surface water is a factor.
Explain how the response action will prevent human and ecological receptor exposure to the groundwater
PCLE zone.
TCEQ-10326/RAP February 2005
19
Response Action Design
Associated Information: Attachment 2A, 2B, 2C
RAP Worksheet 2.0
ID No.:
Page ___ of ____
Report Date:
Response Action Design
Use this worksheet to provide detailed descriptions of the response action. Attach design and layout
drawings and equipment specifications in Attachment 2A.
Media:
List all media to which this information applies. If the response action is different for another media,
complete a separate worksheet.
Provide a detailed description of the response action. Describe the removal action, decontamination,
treatment system(s), and/or physical or institutional control actions that are proposed for each media and
discuss the reasons for choosing the response action(s). Identify and describe any ecological services
analysis and compensatory restoration plan that will be utilized (if so, include the complete ESA and
compensatory restoration plan in Attachment 2C).
Describe all major treatment system components and equipment of the response action. Illustrate the
response action design and provide equipment specifications in Attachment 2A.
List permits or registrations needed to construct or implement the response action, including permits or
registrations needed to conduct studies or tests. For VCP sites, list the permits that would be required if
the site was not in the VCP (required by the VCP).
Permitting/Registration
Type of permit/registration
Permit or registration
Anticipated
Authority
number if already
application date
issued
Identify and discuss the results of any studies or tests, such as pilot studies, feasibility studies, technical
impracticability studies, treatability studies, and/or toxicity studies conducted or proposed to be conducted
at the affected property. Discuss the reason for the study or test and how it verifies the effectiveness and
appropriateness of the chosen response action or documents that a particular response action is not
appropriate for the affected property. Describe how the results of completed studies or tests determined
the design or choice of response action. Attach any separate reports and supporting documentation in
Appendix 3.
TCEQ-10326/RAP February 2005
20
Plume Management Zone
Associated Information: Attachments 2D, 2E
RAP Worksheet 2.1
ID No.:
Page ___ of ____
Report Date:
Complete this worksheet when a PMZ is proposed as part of the response action. Include in Attachment
2D a map of the proposed PMZ with alternate POE(s) and attenuation monitoring points identified and the
current groundwater PCLE zone. If a PMZ is not proposed, do not submit this worksheet.
Groundwater-bearing unit
Repeat this worksheet for each groundwater-bearing unit for which a PMZ is proposed.
Groundwater classification
2
3
Provide justification as to why the PMZ is appropriate in accordance with §350.33(f)(4)(A). Include
supporting documentation in Attachment 2E.
Is the alternate POE proposed to be beyond the current limits of the PCLE zone?
Yes
No
If yes, how far?
(§350.37(l) or (m) as applicable)
Is it to be off-site?
Yes
No
On an off-site property that currently does not contain a residential-based groundwater PCLE zone?
Yes
No
If yes and this is a Class 2 groundwater, provide the basis for concluding that this groundwater does not
have a reasonably anticipated future beneficial use (§350.37(l)(3)).
Is NAPL present?
Yes
No
If so, describe how the response action will achieve the performance criteria in §350.33(f)(4)(E).
If this is a Class 2 groundwater, explain how the response action will ensure that leachate from the
surface soil and subsurface soil PCLE zones will not increase concentration of COCs greater than the
current measured concentrations (at time of RAP submittal). (§350.33(a)(2))
Provide the basis that the COCs will not migrate beyond the downgradient boundary of the PMZ at
concentrations above the critical PCL. Include supporting documentation in Attachment 2E.
Describe the methods used to determine that there are no artificial penetrations which can allow COCs to
migrate from the groundwater PCLE zone to currently unaffected groundwater-bearing units. Include
supporting documentation in Attachment 2E.
TCEQ-10326/RAP February 2005
21
Plume Management Zone
Associated Information: Attachments 2D, 2E
RAP Worksheet 2.1
ID No.:
Page ___ of ____
Report Date:
List the attenuation action level determined for each attenuation monitoring point. Illustrate the proposed
attenuation monitoring points and the groundwater PCLE zone on the map in Attachment 2D. Include all
calculations and other methods of determining the attenuation action levels in Attachment 2E.
COC
Attenuation Monitoring
Attenuation Action
Attenuation Action
Point (well number)
Level
Level limited by
AirGW
(mg/L)
Inh-V or existing
COC concentration?
Y/N
TCEQ-10326/RAP February 2005
22
Waste Control Unit
Associated Information: Attachment 2F
RAP Worksheet 2.2
ID No.:
Page ___ of ____
Report Date:
Use this worksheet to document the use of a waste control unit to modify the groundwater response actions
(§350.33(f)(2)). Provide a map in Attachment 2F of the waste control unit overlying the PCLE zone. Include
proposed institutional controls in Appendix 4. If this modification does not apply, do not submit this worksheet.
Is the waste control unit an existing unit?
If yes, provide: the permit number
description
status
active
Yes
No
closed
Describe how the existing or proposed WCU meets the definition set forth in §350.4(a)(91).
If the WCU is proposed, identify any applicable permitting process that must be completed prior to operation of
the WCU.
Has the applicable permit been pursued yet?
If not, when will this be initiated?
TCEQ-10326/RAP February 2005
Yes
No
23
Technical Impracticability
Associated Information: Attachment 2G
RAP Worksheet 2.3
ID No.:
Page ___ of ____
Report Date:
Use this worksheet to justify the use of technical impracticability (TI) to modify the groundwater response
objectives. Also complete Worksheet 2.2 to propose a plume management zone for the TI area. Include a
map of the groundwater PCLE zone and area of technical impracticability in Attachment 2G. Include in the
attachment any other documentation needed to make the justification. If technical impracticability is not
proposed as part of the response action, do not submit this worksheet.
Describe the groundwater PCLE zone and demonstrate in accordance with Guidance for Evaluating the
Technical Impracticability of Ground-Water Restoration (EPA OSWER Directive 9234.2-25), unless otherwise
approved by TCEQ, why it is technically impractical to reduce the COC concentrations to the critical PCLs,
taking into account all currently available remediation technologies, and hydrogeologic and chemical-specific
factors. Identify the specific COCs and list the PCLs that cannot be achieved.
Are there groundwater COCs in excess of the critical PCLs beyond the TI area?
Yes
If yes, make sure removal/decontamination actions are documented in Worksheet 1.0.
No
Will actions be required or already completed to prevent COC migration outside the area of technical
impracticability and/or outside the existing boundary of the groundwater PCLE zone?
Yes
No
If yes, make sure removal/decontamination actions are documented in Worksheet 1.0.
TCEQ-10326/RAP February 2005
24
RAP Worksheet 2.4
Institutional Control
ID No.:
Associated Information: Appendices 4, 5
Page ___ of ____
Report Date:
Complete this worksheet if an institutional control will be used as part of the response action. Include a draft of the proposed institutional controls
in Appendix 4. Provide a list of landowners from whom landowner concurrence will be requested, as necessary, in Appendix 5.
Specify the property for which this applies.
Repeat this worksheet for each different property for which an institutional control will be used.
Type of Institutional Control1
Property Ownership
Institutional Control
Deed
Notice
Restrictive
VCP
Equivalent
Check if
Check if the
Covenant Certificate of
zoning or
Completion governmental pertinent tract pertinent tract of
of land is
land is owned by
ordinance
owned by the
an innocent
person
owner or
operator
Document use of commercial/industrial land use
(§350.31(g))
Document use of physical or institutional control under Remedy
Standard B §350.31(g))
Document notice of on-going long term response action
(§350.31(h))
Document use of occupational inhalation criteria as RBELs
(§350.74(b)(1))
Document variance from the default exposure factors
(§350.74(j)(2)(L))
Document the use of a non-default soil exposure area
(§350.51(l)(3)&(4))
Document WCU exclusion area (§350.33(f)(2))
Document establishing a PMZ (§350.33(f)(4)(C)(I))
Document the demonstration of technical impracticability
(§350.33(f)(3)(F))
Relocation of soils containing COCs for reuse (§350.36(b)(4)
and (c)(4))
1
2
Check the appropriate box(es) to indicate the type of institutional control required for the proposed response action.
Specify date or amount of time after RAP approval.
TCEQ-10326/RAP February 2005
25
Anticipated
Filing Date2
Performance Measures and
Potential Problems
RAP Worksheet 3.0
ID No.:
Page ___ of ____
Report Date:
Performance Measures
List and describe the performance measures for each environmental medium containing a PCLE zone
that will be used to determine if reasonable progress is being made by the response action in a timely
manner. Use these measures to document effectiveness of the response action in the RAER.
Potential Problems
Complete the table for the response action. When the response action consists of several
components or multiple actions, complete one table for each major component or action.
Response Action Name/Designation:
List the potential problems that might be reasonably anticipated for the response action, describe the
impact of each problem, and the response to the problem.
Description of the Potential
Impact
Will this
Corrective Response
Problem
cause a
response
action
failure?
Yes
No
TCEQ-10326/RAP February 2005
26
Monitoring and Sampling
Associated Information: Attachment 3A
RAP Worksheet 3.1
ID No.:
Page ___ of ____
Report Date:
List the monitoring and sampling of COC concentrations or other parameters that will be conducted during the response action. Illustrate the
monitoring or sampling locations in Attachment 3A. If statistics or geostatistics will be used, provide details in Appendix 7. If monitoring or observation
wells will be constructed for the response action, provide well construction details in Attachment 2B if not previously provided.
Monitored Media
COC1
Other
Sampling
Sampling
Depth/Height4 Analytical or Field
Sampling or
parameter
Method2
points or
(ft.)
Screening
Monitoring
(specify)
locations3
Method
Frequency5
Surface Soil
Subsurface Soil
Groundwater
Surface water
Sediment
Air
Other Media (specify)
Explain the reasons for the above-listed monitoring and sampling plan.
1
Specify the COCs to be monitored in this media. List either type of COC (such as VOCs, metals) if all the COCs of that type will be monitored the same way.
Describe the sampling or monitoring methods and QC procedures in Appendix 1 unless the proposed sampling or monitoring procedure is the same as the sampling
or monitoring procedure described in the APAR.
3 Specify the sampling or monitoring point, such as the specific monitor well or general sampling or monitoring location.
4 Specify the depth or height of the sampling or monitoring points.
5 Specify the frequency at which this monitoring or sampling will occur.
2
TCEQ-10326/RAP February 2005
27
Operation and Maintenance
RAP Worksheet 3.2
ID No.:
Page ___ of ____
Report Date:
Use this worksheet to describe the operation and maintenance (O&M) activities for each response action. In
situations where the response action consists of more than one major component, for clarity one worksheet
can be completed for each major component.
Response Action Name/Designation:
List all portions of the response action to which this information applies.
Describe the O&M and inspection activities that will be required to operate and maintain response action
components.
List and discuss the key operating parameters for a properly functioning response action. Address how
changes in these parameters will result in operating changes, providing sufficient detail to explain how the
operator will know the component is functioning properly.
List the routine tasks required to operate the response action.
List the routine tasks required to maintain the response action, including scheduled inspections, maintenance,
and component replacement.
TCEQ-10326/RAP February 2005
28
Confirmation Sampling Plan
Associated Information: Attachment 4A
RAP Worksheet 4.0
ID No.:
Page ___ of ____
Report Date:
List the COCs and other parameters that will be sampled to confirm completion of the response action. Illustrate the monitoring or sampling locations
in Attachment 4A. If monitoring or observation wells will be constructed for the response action, provide well construction details in Attachment 2B if
not previously provided. If needed, describe the sample collection and handling methods, if not previously provided, in Appendix 6.
Media
COC1
Other
Sampling
Sampling
Depth/height
Analytical
Sampling Frequency
parameter
Method
points2
Method
(ft.)
(specify)
Surface Soil
Subsurface Soil
Groundwater
Surface water
Sediment
Air
Other media
(specify)
Explain the reasons for the above-listed sampling plan. Discuss statistical or geostatistical methodology(ies) which will be applied, if any, in the data
collection process. Discuss any assumptions made in the statistical/geostatistical assessment, and how they will be met.
1
2
Specify either a specific COC or type of COC (such as VOCs, metals).
Specify the sampling point to the degree it is known, (for example, MW-1, or near former boring #2).
TCEQ-10326/RAP February 2005
29
Post-Response Action Care
Associated Information: Attachments 5A-5C
RAP Worksheet 5.0
ID No.:
Page ___ of ____
Report date:
Complete this worksheet only if Remedy Standard B will be used.
What is the proposed initial post-response action care period? (default 30 yr.)
years
If the proposed initial post-response action care period is less than 30 years, provide a technical justification in
accordance with §350.33(h).
What is the foreseeable land use during the post-response action care period?
Describe how the future use of the property will not compromise the integrity of the physical controls, will not
interfere with the function of the monitoring systems, will not pose a threat to human health or the environment,
and will be in accordance with any institutional controls.
Briefly describe the proposed post-response action care activities. Describe the type of monitoring and/or
inspections to be performed. Discuss the rationale for not including COC(s) analyzed during the response
action, monitoring or sampling point location, frequency of monitoring and/or inspections, and the duration of
the monitoring program.
Will PRAC sampling procedures be the same as those as previously documented
for monitoring and/ or confirmation sampling?
Yes
No
If no, provide in Appendix 6 a description of the monitoring or sampling collection procedures to be conducted
during the post-response action care period.
Cost Estimate
Complete this portion of the form only if a physical control is proposed (installed hydraulic control system,
slurry wall, cap, etc.). Provide in Attachment 5B a detailed cost estimate for a third party to operate and
maintain the physical control during the PRAC period, based on current dollar amount.
Specify the physical control to which this information applies
Complete this worksheet for each physical control that will be used as part of the response action.
What is the total estimated annual cost of O&M for the PRAC period?
$
What is the total estimated cost for a third party to perform PRAC activities?
$
Identify the type of financial assurance mechanism to be used, and the contact person managing fiduciary
responsibility, if known.
Does the person meet the criteria and definition of a small business? (see §350.33(n))
Yes
No
If yes and the person desires to pursue the reduced amount of financial assurance, provide a legally binding
affidavit as Attachment 5C. Include in the affidavit the information requested in 30 TAC §350.33(l), (m), and
(n). An example affidavit is attached in the instructions.
TCEQ-10326/RAP February 2005
30
Implementation Schedule
RAP Worksheet 6.0
ID No.:
Page ___ of ____
Report Date:
Document the proposed schedule for implementing the response action. Include all major response action
activities through the life of the project, including all removal, decontamination, and control actions, component
installations, O&M, monitoring, and post-response action care activities.
Implementation of Response Action
Start
Finish
Duration
(specify component or action)
List the proposed schedule for report submittals. Add additional lines if more reports than listed will be needed
to complete the response action.
Reports
Submittal date
Response Action Effectiveness Report (RAER)
RAER submittal number 1
RAER submittal number 2
RAER submittal number 3
Response Action Completion Report (RACR)
Post-Response Action Care Report (PRACR)
PRACR submittal number 1
PRACR submittal number 2
PRACR submittal number 3
TCEQ-10326/RAP February 2005
31
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